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RECD JUL 24 2015 PACTIV <br /> Foodservicel Food Packaging <br /> waste. Disposal records for the disposal of hazardous waste paint solids were available at the <br /> time of inspection. <br /> Pactiv Response:The drip pans noted during the inspection are used for collecting ink from <br /> the BHS printing press, not paint. The ink and the associated plastic lining are disposed of <br /> with the other ink solids waste, which is managed as a Non-RCRA CA hazardous waste. <br /> 110 <br /> It was not clear if all personnel who hazardous waste received appropriate training. <br /> Response: Waste training has been provided to key employees involved with hazardous <br /> waste management. A copy of the waste training presentation and the most recent training <br /> roster are provided as Attachment 5. <br /> 115 <br /> Following copies of uniform manifests for the disposal of hazardous waste for 2013 were not <br /> found on site: <br /> 000780266VES, 00093057VES, 009434199JJK, 009434331JJK, 009434474JJK, 010835077JJK, <br /> 01158217JJK, and 011570275JJK. <br /> Pactiv Response:These manifests were inadvertently misfiled. Copies of these manifests are <br /> provided as Attachment 6. In addition,to ensure our waste manifest files remain up-to-date <br /> and complete,we have implemented a standard monthly review of our waste manifest files. <br /> This review is included as part of our internal automated environmental task reminder <br /> system. <br /> 123 <br /> A submission to the California Electronic Reporting System (CERS)for the hazardous waste <br /> program has not been made. <br /> Response: Since we are not RCRA Large Quantity Generator, we do not believe that any <br /> changes to our Business Plan, regarding information regarding Hazardous Waste Generator <br /> Status, are necessary. <br /> 301 <br /> One (non-empty) mineral oil storage tote, located inside the outdoor hazardous waste storage <br /> area, had some oily staining around its base. <br /> Pactiv Response:This area has been cleaned up and procedures have been put in place to <br /> mitigate future occurrences. In addition,this issue has been placed on a monthly inspection <br /> checklist. A professional environmental company was hired to clean this area. The waste is <br /> currently staged on site and will be properly disposed of as a Non-RCRA California Hazardous <br /> Waste. <br /> Metal fines were noted on the floor around the bench grinding equipment located in the <br /> maintenance shop (parts area). <br />